Last Updated: May 13, 2024

We, Glu.ai (“we”, “us”, “our” “Company”) are the owners of the website www.glu.ai (“Website”) the software as a service (SaaS) solution (“Product”). The Product is a creative management software as a service (SaaS) platform for e-commerce merchants which enables businesses to create content for marketing campaigns for their websites, platforms, marketplaces, and social media pages (“Services”). The Website and the Product are collectively referred to as the “Platform". The Website showcases the Offerings of the Company.

Glu.ai respects data privacy rights and has created this Privacy Notice in line with its commitment to privacy. This Privacy Notice (“Privacy Notice”) sets forth how we collect, use and protect the personal data collected on this Platform.

PLEASE READ THIS PRIVACY NOTICE CAREFULLY. BY CLICKING ON THE CONSENT CHECK BOX, AND BY ACCESSING AND USING THE GLU.AI WEBSITE, YOU AGREE TO THE TERMS OF THIS PRIVACY NOTICE OUTLINED BELOW. YOU HEREBY GIVE PERMISSION TO GLU.AI TO PROCESS PERSONAL DATA FOR THE PURPOSES AND WITHIN THE SCOPE DEFINED HEREIN. IF YOU DO NOT AGREE TO THE TERMS OF THIS NOTICE, PLEASE DO NOT ACCESS OR USE THE PLATFORM.

IF YOU ARE ACCESSING THE WEBSITE ON BEHALF OF A THIRD PARTY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH THIRD-PARTY TO THE TERMS AND CONDITIONS OF THIS PRIVACY NOTICE AND, IN SUCH AN EVENT YOUR USE OF THE WEBSITE SHALL REFER TO USE BY SUCH THIRD PARTY. IF YOU DO NOT HAVE SUCH AN AUTHORITY (TO PROVIDE ANY PERSONAL DATA OF A THIRD PARTY) OR DO NOT AGREE TO THE TERMS OF THIS PRIVACY NOTICE, THEN YOU SHOULD REFRAIN FROM USING THE PLATFORM.‍

This Privacy Notice is an electronic record in the form of an electronic contract and is construed in accordance with data protection laws of the applicable jurisdictions.

1. Definitions

1. “User(s)” “you”, “your” shall mean individuals that visit/use/access the Platform;
2. “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data;
3. “Processor” means a natural or legal person, public authority, agency, or other body which processes Personal Data` on behalf of the Controller;
4. “Personal Data” means any information relating to an identified or identifiable natural person.‍

2. Personal Data Collected by the Glu.ai

We may receive your Personal Data in the following cases:

1. Website: You may provide us with information when you access and/or use our Website, contact us through the  Website, join the waitlist for our Product, including your name, email address, contact number, IP address, browser type, ISP, referring/exit pages, platform type, date/time stamp, number of clicks, domain name and country/state of all visitors to the site, location information.
2. Account Creation: When you create an account to avail our Services, we may collect your information like your name, contact number, email address, company name and country to complete the account signup process.
3. Contact Us: We may also collect, store and use your Personal Data, such as name, email address, contact number, and organisation name, when you contact us on the Platform or reach out to us via email.
4. Log File Information: When you use our Platform, we may collect information including but not limited to the internet protocol (IP) address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about users of our Platform.
5. Information from Third-Party Applications: We may receive information about you from third parties, if you access the Services through a third-party connection or log-in, such as Facebook or Google, that third party may pass certain information about your use of its service to us. This information could include, but is not limited to, the user ID associated with your account, an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Service. You may also unlink your third party account from the Service by adjusting your settings on the third party service.

3. Cookies

We use cookies and/or similar in-house and third-party tracking tools to track user traffic patterns. Tracking tools also used are beacons, tags and scripts to collect and track information and to improve and analyze our Platform. You may choose to disable cookies through your browser settings. For more information, please refer to our cookie policy here.

4. Accuracy of information

The User undertakes that he shall be solely responsible for the accuracy, correctness, or truthfulness of the Personal Data shared with us whether of its own or any third party. In the event the User is sharing any Personal Data on behalf of a third person, the User represents and warrants that he has the necessary authority to share such Personal Data with the Company, obtained a written consent from such third party and the Company shall not be responsible for verifying the same. The User understands and acknowledges that such Personal Data shall be subject to the terms and conditions of this Privacy Notice.‍

5. Anonymized Data

We may also use your Personal Data collected to create aggregate anonymized data. We shall ensure that such anonymized data will not be directly identifiable to you or to the Personal Data shared with us. We may use this anonymized data for any purpose including but not limited to conduct research, analytical purposes, commercial usage, enable advancements in technology. However, this anonymized data will not be used to train artificial intelligence models developed by us or third parties or to improve our Platform. By visiting or using the Platform, you provide us with the right to use your Personal Data to create anonymized data sets and use it for our business purposes.

‍6. Use/Purpose of collecting Personal Data

We use the Personal Data for the following purposes:

1. to inform you about our Services and to respond to your requests ;
2. for the creation or development of business intelligence or data analytics in relation to the services provided by us;
3. to provide you with a better experience when you access our Platform and to improve the Services;
4. to maintain and manage our Platform;
5. to provide support for operations, provision of Services;
6. to manage our relationship with you;
7. for internal record keeping;
8. and to comply with our legal or statutory obligations.

7. Disclosures

We do not sell, rent, share, distribute, lease or otherwise provide your Personal Data to third parties, without your prior consent. Keeping this in mind, we may disclose your Personal Data in the following cases:

1. Affiliates: We may provide your Personal Data to our affiliates to enable them to improve the Services, provide feedback and respond to their queries.
2. Service Providers: We may share your Personal Data with the service providers who work with us in connection with operating the Platform and/ or providing the Services. All such service providers are subject to stringent confidentiality restrictions consistent with this Privacy Notice.
3. Merger or Acquisition: We may transfer your Personal Data if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Website, to a third party. Any such third party or resultant entity that receives your Personal Data shall have the right to continue to use your Personal Data in line with the purposes set out herein.
4. Safety, Legal and Regulatory Authorities: We may disclose your Personal Data if we believe that we are required to do so: (a) by law; (b) to comply with legal process or governmental requests; (c) to enforce our agreements; (d) to protect our operations; (d) to protect the rights, privacy, safety or property of the Company, you or others; (e) to protect our reputation and (f) to permit us to pursue available remedies or limit the damages that we may sustain.

8. Data Retention

We will retain User’s Personal Data as long as it is required to be retained for the purpose of provision of the Services on our Platform. We may also retain and use User’s Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9. Security

We are committed to maintaining information security and protecting customer data from potential breaches. Although we provide appropriate firewalls and protections, we cannot warrant the security of Personal Data transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we will take necessary measures to mitigate such events.

10. Your Rights

You have the following rights under the applicable data privacy laws:

• right to access Personal Data in our possession,
• right to have us rectify or modify any such Personal Data,
• right to have us erase/delete your Personal Data,
• right to restrict us from processing such Personal Data,
• right to object to our use of Personal Data,
• withdraw consent at any time where we are relying on consent to process Personal Data.
• Depending on the nature of the request, we may ask you to complete a Personal Data request form or seek certain details to verify the request. All requests for Personal Data will be handled within a reasonable period of time. If you would like to exercise ANY of these rights, please contact infosec@glu.ai.

11. Information For EU And UK Visitors

Residents of the European Union (“EU”) and United Kingdom (“UK”) should note that this Privacy Notice has been updated in accordance with the requirements of the EU General Data Protection Regulation (the “GDPR”) and the UK GDPR, the United Kingdom Data Protection Act 2018, the Privacy and Electronic Communications Regulations, and any regulation superseding any of the foregoing (“UK Privacy Laws”). As per the provisions of the GDPR and UK Privacy Laws we shall be considered the Controllers of the Personal Data collected as a result of your use / access of the Website and Processors of the Personal Data collected as a result of your use / access of the Website.

Legal Basis (for EU residents and UK residents): We will not process your Personal Data without a lawful basis to do so. We will process your Personal Data only on the legal bases of consent, contract, or on the basis of our legitimate interests, provided that such interests are not overridden by your privacy rights and interests.

Transfer of your personal data across borders (for EU Residents): The Personal Data we collect (of EU and UK residents) is stored on servers located in the EU region or in India. Personal Data might be processed outside the EU and UK. We collect and transfer Personal Data outside the EU and UK in accordance with the provisions of the GDPR and UK Privacy Laws. If you have questions, please contact us at infosec@glu.ai.

Your Rights (For EU and UK Residents):

You have the right to request us:

1. to let you know what Personal Data belonging to you,
2. we hold in our possession,
3. withdraw consent at any time where we are relying on consent to process your Personal Data,
4. right to have us rectify or modify any such Personal Data,
5. right to have us erase/delete your Personal Data,
6. right to restrict us from processing such Personal Data,
7. right to object to our use of your Personal Data,
8. you have the right to lodge a complaint with a data protection authority.

UK residents have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. We may need to request specific information from you to help us confirm your identity or also contact you for further information in relation to your request. If you would like to exercise ANY of these rights, please contact infosec@glu.ai.

Governing Laws: For any EU and UK residents, this Privacy Notice shall be governed respectively by the provisions of the GDPR and UK Privacy Laws.

12.California Residents Rights

If you are a California resident, you have the rights outlined in this section. If you are a California resident and there are conflicts between this section and any other provision of this Policy, the portion that is more protective of your Personal Data shall control. If you have any questions about this section or whether any of the following applies to you, please write to us at infosec@glu.ai.

We do not sell, rent, distribute, lease or otherwise provide your Personal Information to third parties, without your prior consent.

Access: You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:

• The categories of Personal Data that we have collected about you;
• The categories of sources from which that Personal Data was collected;
• The business or commercial purpose for collecting or selling your Personal Data;
• The categories of third parties with whom we have shared your Personal Data; and
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient.

Deletion: You have the right to request that we delete the Personal Data that we have collected from you. Under the California Consumer Privacy Act of 2018 (“CCPA”), this right is subject to certain exceptions. For example, we may need to retain your Personal Data to provide you with the services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights: To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (this will require you to send an email from the account in question or login credentials), and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within a reasonable time of receipt. You may submit a Valid Request by emailing us at infosec@glu.ai.

We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to do, and we may request a copy of this written permission from your Authorized Agent when they make a request to exercise your rights on your behalf.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.

13. Links to other websites/ platforms/ applications

Our Platform may contain links to various other third-party websites/ platforms/ applications of your interest. Please note that the Company has no control over such third party websites/ platforms/ applications and you will be accessing these websites/ platforms/ applications at your own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites/ platforms/ applications and those are not governed by this Privacy Notice. You should exercise caution and look at the privacy policy applicable to such websites/ platforms/ applications.

14. Changes to the Notice

Glu.ai reserves the right to modify or amend this Privacy Notice at its own discretion.  Please revisit this page periodically to stay aware of any changes to this Privacy Notice, which we may update from time to time. If we modify this Privacy Notice, we will make it available through the Platform and indicate the date of the latest revision. If such modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change via email or through our Platform.

15. Contact Us

We are open to your questions, comments, concerns, grievances and suggestions regarding this Privacy Notice or wish to withdraw your consent in relation to the processing of your Personal Data you can reach out to our appointed grievance redressal officer or data protection officer Rahul Pandey at infosec@glu.ai.

Office address:‍

Glu Pte Limited

160, Robinson Road #20-03

Singapore - 068914

Cookies and tracking

Cookies Policy

1. Introduction‍

We, Glu.ai (“Company”, “we”, “us”, “our”) may use cookies or similar technologies to analyse information about your use of our website www.glu.ai (“Website”). We are committed to protecting the privacy and security of your personal information. We advise you to carefully read this cookie policy (“Policy”), together with the Company’s Privacy Policy so that you are aware of the cookies and technologies used as well as how we treat your personal information.‍

2. What are Cookies? ‍

Cookies are alphanumeric files which are placed on to your device when you visit a website. It allows us to recognize your device and store some information about your preferences or past actions, analyze trends, to learn about our user base, operate and improve our services and provide you with a better experience when you visit our website.‍

3. Types of Cookies Used

1. Permanent cookies – Permanent cookies helps us recognize you as an existing user, so it’s easier for you to return to the website without signing in again. After signing in, the permanent cookies stay on your browser and will be read when you return on to our sites. These remain on your computer/device for a pre-defined period.

2. Session cookies – Session cookies only last for as long as the session exists (they get erased when the user closes the browser).As for the domain to which it belongs, there are either:

a. First-party cookies: These cookies are set by the web server of the visited page and share the same domain.

b. Third- party cookies: These cookies are placed by third party on your device and may provide information to us and third parties about your usage of the website.

c. Analytical Tools:

Google Analytics: We use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies, text files that are stored on your computer and enable analysis of your use of the website. The information generated by the cookies about your use of the website are usually transferred to a server of Google in the US and stored there. We do not control third party cookies.  You can also prevent the data generated by the cookie and related to your use of the website to Google and the processing of these data by Google, by visiting the following link. (https://tools.google.com/dlpage/gaoptout).‍

4. Use of Cookies

We use personal information captured through cookies to make your interaction with us faster and more secure. They may be used for the following purposes:

1. Preferences – Cookies allows the website to remember information that changes the way the site behaves or looks, such as your preferred language or the region you are in. Remembering your preferences enables us to personalize and display advertisements and other contents for you.
2. Security/Optimization – Cookies allow us to maintain security by authenticating users, preventing fraudulent use of login credentials and protect user data from unauthorized parties. We may use certain type of cookies allow us to block many types of attacks, such as attempts to steal content from the forms present on the website.
3. Processing – Cookies enable the website to work efficiently. Basis such cookies, we are able to deliver services that a website visitor expects, like navigating around web pages or accessing secure areas of the website.
4. Advertising – We use cookies to make advertising more engaging to our users. Some common applications of cookies are made to select advertising based on what’s relevant to you, to improve reporting on campaign performance and to avoid showing ads you would have already seen. Cookies capture information about how you interact with the website, which includes the pages that you visit most.
5. Communication – We may use information collected via cookies to communicate with you, for sending newsletters, seeking your opinion and feedback and providing you services and promotional materials.
6. Analytics and Research – We may use cookies to better understand how people use our products/services so that we can improve them.

5. Disabling Cookies

You can decide whether to accept or not to accept cookies. You can disable the cookies by adjusting the settings on your browser (see your browser Help for how to do this). Disabling cookies may affect the functionality of our website.

6. Changes to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the website and indicate the date of the latest revision.

7. Contact us

If you have any questions or concerns regarding this Policy, you can contact us at infosec@glu.ai.